by James McDonald
November 14, 2018 – 7:00 p.m.
NYU School of Law: Program on Corporate Compliance & Enforcement
As Prepared for Delivery
INTRODUCTION
Thank you for that introduction. I’m happy to be back here at NYU as part of the Program on Corporate Compliance & Enforcement (PCCE). Over the years, the PCCE has brought together some of the best thinking in the enforcement, business, and academic community to develop a richer and deeper understanding of the causes of corporate misconduct, and how enforcement and compliance programs can most effectively deter it. The result is that the work here at the PCCE has been a driver of some of the most significant developments in Enforcement and Compliance.
We’ve followed these developments closely at the Commodity Futures Trading Commission (CFTC). At every stage of our agency’s history, we’ve sought to bring impactful enforcement actions in the markets we regulate, and to ensure we stand ready to meet the challenges presented as these markets continue to evolve. Our most recent challenges have included responding to the dramatic expansion of our jurisdiction under Dodd-Frank in the wake of the financial crisis. Under David Meister, the first post-Dodd-Frank Director of Enforcement, the Division literally wrote the rules that set out some of our new enforcement jurisdiction. With the next Director, Aitan Goelman, the Division brought first-of-their-kind cases under these new rules. And under both Directors’ leadership, we began to define our major priorities and to develop some of the initiatives we rely on today, like the Division’s cooperation program. Thanks to their hard work and that of the dedicated career civil servants who staff the Division, we’re well positioned today to continue to build on those priorities and initiatives. As part of that effort, we’re constantly surveying the enforcement world to identify best practices and to incorporate them into our program. Continue reading →
